Court allows Ohio citizenship proof rule at BMV

What the court decided

A federal appeals panel ruled 2-1 on Sept. 23 that Ohio may enforce its proof-of-citizenship requirement for voter registration at Bureau of Motor Vehicles offices. The decision reversed an August order from U.S. District Judge Solomon Oliver Jr. that had blocked the law.

Ohio lawmakers passed the measure in 2025. It requires BMV registrars to offer voter registration only to people who show proof of U.S. citizenship or previously submitted citizenship documents to the agency. The Ohio Secretary of State’s Office said that generally had already been the BMV’s standard practice.

Republican Secretary of State Frank LaRose said the ruling upheld the state law intended to ensure that only U.S. citizens register to vote in Ohio.

Why the panel reversed the order

Judges Whitney Hermandorfer and John Nalbandian formed the majority. They found that the individuals challenging the requirement were not prevented from registering to vote.

The majority also found that blocking the law would require the BMV to change its electronic driver’s license application system and train employees under new procedures, costing.

Judge Kevin Ritz dissented. He wrote that the individuals could still have been harmed by the BMV’s refusal to offer them voter-registration forms when they did not submit citizenship documents, even though they eventually registered.

Who challenged the law

The Elias Law Group filed the case for the Ohio Alliance for Retired Americans and Red Wine and Blue. The challengers argued that the requirement created registration barriers for new Ohio residents, older residents and women whose names changed after marriage or divorce.

The published account of the ruling says the challenge focused on voter-registration services offered through the BMV.